Ukraine's State Fiscal Service (SFS) recently published a guidance letter on the eligibility of a Cyprus resident for treaty benefits on dividends received from a wholly-owned legal entity in Ukraine. Under the 2012 Cyprus-Ukraine tax treaty, a 5% withholding tax rate applies if the beneficial owner holds at least 20% of the paying company's capital or the beneficial owner has invested the equivalent of at least EUR 100,000 in the acquisition of shares or other rights in the paying company. Otherwise, the rate under the treaty is 15%, which is also Ukraine's withholding rate under domestic law. Given that the...